Swiss Transparency Act: All Information on the Transparency Register

Reporting to the transparency register: do it yourself, hire a fiduciary or use software?

Since 1 October 2026, Swiss companies have been required to report their beneficial owners to the transparency register. This article explains the respective roles of the board of directors, fiduciaries and software. A cost example for a company limited by shares with several shareholders compares the different approaches. It also explains why collecting and updating information accounts for most of the work.
October 15, 2026
9 Min.

Latest posts

AllDue Diligence & Documentation
Reporting & Deadlines
Beneficial Owners
Reporting Obligations
Transparency Register
Reporting Process
Controls & Sanctions
Advisors & Financial Intermediaries
Who is affected?
4 Min.

No Correct Report to the Transparency Register Without a Sanctions Check

The transparency register requires legal entities not only to identify their beneficial owners but, in certain cases, also to provide information on the entire chain of control. One trigger is a freezing measure imposed on a beneficial owner under the Embargo Act or the Foreign Illicit Assets Act. Whether such a case exists can only be established through a sanctions check. This article explains the legal basis, the practical consequences of a match and how Konsento integrates this verification step as standard into the share register and the reporting process.

3 Min.

Report to the transparency register – who bears responsibility and what a request from the authorities means

LETA requires non-listed Swiss legal entities to identify their beneficial owners and report them to the transparency register themselves and on time. As a rule, there is no automatic invitation from the authorities, apart from a one-off notice from the commercial register office during the transitional period. This article explains the situations in which the authority maintaining the register issues a formal request, the fees involved and the consequences – including possible fines – if a deadline set by the authority is missed.

5 Min.

Simplified reporting requirements in the transparency register for listed or institutional shareholders

LETA fully excludes listed companies, pension institutions and legal entities that are at least 75 percent held by public bodies from its scope. For companies that do not fall under these exemptions but are nevertheless held by a listed company, a pension institution or a contractual investment fund, LETO provides for specific simplifications. These simplifications reduce the identification and reporting obligations for the relevant ownership interest to basic information about the holding institution, without requiring a natural person to be identified as the beneficial owner. The article also explains how an exempt subsidiary should respond if the authority maintaining the register is unaware of the exemption and issues a request. For all other ownership interests in the company, the ordinary rules continue to apply unchanged.

5 Min.

Reporting to the transparency register – what the electronic platform handles and what the company itself must do

The transparency register and the government's EasyGov reporting platform have a clearly defined role. They receive a completed report, ensure that only authorised persons act, and make the information available to entitled parties. By contrast, determining who qualifies as a beneficial owner and preparing the related documentation take place beforehand within the company and cannot be carried out or made up for in the input form. This article shows where this division of responsibilities lies, why an inaccurate report may later become visible through discrepancy reports and notes, and how identification, documentation and reporting can be combined into an end-to-end process.

7 Min.

When a shareholders’ agreement constitutes acting in concert for the transparency register

The new LETA does not only cover shareholders with an ownership interest of more than 25%, but also groups of persons acting in concert. This article explains that the interpretation of this concept is guided by decades of Swiss stock exchange law practice and applies the categories developed there to shareholders’ agreements and co-investor syndicates in non-listed Swiss companies limited by shares. A practical example shows that members of investor groups with coordinated voting commitments, veto rights and board rights may need to be reported individually as beneficial owners based on the group’s aggregate ownership interest, even where no individual person reaches the 25% threshold. Finally, the article shows how companies can prepare for this reporting obligation with a structured data basis and a guided identification process.

4 Min.

What Swiss Startups Need to Know About Their Reporting Obligations to the Transparency Register

As of 1 October 2026, Swiss startups too must report their beneficial owners to the new transparency register. This article shows why this obligation is more complex for startups than for classic SMEs, for instance because of shareholders' agreements, investor syndicates, convertible loans, and shares with different voting rights. It explains when holdings under 25 percent also become reportable, and how the thresholds of 25, 50, and 75 percent trigger later reports of changes. It also looks at how startups can prepare for this recurring reporting obligation in a structured way already now.